DRAFT 

DCAS-PER-043, SUBTASK 4: 

REVIEW OF FOUR CASES REASSESSED FOR THE 

EVALUATION OF REVISIONS TO ORAUT-OTIB-0005, 

“INTERNAL DOSIMETRY ORGAN, EXTERNAL DOSIMETRY 

ORGAN, AND IREP MODEL SELECTION BY ICD-9 CODE”

Contract No. 211-2014-58081

Revision 0 

U. Hans Behling, PhD 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182

December 2014 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted. 
Effective Date:

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S. Cohen & Associates:

Technical Support for the Advisory Board on

Radiation & Worker Health Review of

NIOSH Dose Reconstruction Program

Document No.:

DCAS-PER-043, Subtask 4 Review

Effective Date: 

Draft – December 17, 2014

DCAS-PER-043, SUBTASK 4:

REVIEW OF FOUR ADVISORY BOARD 

CASES REASSESSED FOR THE 

EVALUATION OF REVISIONS TO ORAUTOTIB-0005, “INTERNAL DOSIMETRY 

ORGAN, EXTERNAL DOSIMETRY 

ORGAN, AND IREP MODEL SELECTION 

BY ICD-9 CODE”

Page 2 of 28

Task Manager:

________________________ Date: ___________

U. Hans Behling, PhD

Supersedes:

N/A

Project Manager:

________________________ Date: ___________

John Stiver, MS, CHP

Reviewer:

John Stiver 

Record of Revisions

Revision 

Number Effective Date Description of Revision

0 (Draft) 12/17/2014 Initial issue.
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TABLE OF CONTENTS 

Abbreviations and Acronyms ......................................................................................................... 4

1.0 Relevant Background Information ...................................................................................... 5

2.0 Review of DCAS-PER-043 Issues for [Case A]................................................................. 9

2.1 Relevant Background Information ............................................................................ 9

2.2 SC&A’S Comments/Findings ................................................................................... 9

3.0 Review of DCAS-PER-043 Issues for [Case B]............................................................... 15

3.1 Relevant Background Information .......................................................................... 15

3.2 SC&A’S Comments and Findings .......................................................................... 15

4.0 Review of DCAS-PER-043 Issues for [Case C]............................................................... 17

4.1 Relevant Background Information .......................................................................... 17

4.2 SC&A’S Comments and Findings .......................................................................... 19

5.0 Review of DCAS-PER-043 Issues for [Case D]............................................................... 24

5.1 Relevant Background Information .......................................................................... 24

5.2 SC&A’S Comments and Findings .......................................................................... 24

6.0 Summary Conclusions ...................................................................................................... 26

References ..................................................................................................................................... 27

LIST OF EXHIBITS 

Exhibit 1: List of Claims Reassessed by NIOSH under DCAS-PER-043 ..................................... 8

Exhibit 2: Metastatic Cancer Fact Sheet (Page 1) – National Cancer Institute ........................... 12

Exhibit 3: Memo from Ronald E. Goans RE: NIOSH [Case A] ................................................ 13

Exhibit 4: Note to Reviewers ....................................................................................................... 14

Exhibit 5: NIOSH’s Reassessment Report for [Case B] .............................................................. 16

Exhibit 6: NIOSH’s Reassessment Report for [Case C] .............................................................. 18

Exhibit 7: Bile Duct Cancer Description from American Cancer Society .................................. 20
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ABBREVIATIONS AND ACRONYMS 

ACS American Cancer Society 

Advisory Board Advisory Board on Radiation and Worker Health 

BCC basal cell carcinoma 

CADW Chronic Annual Dose Workbook 

CCL chronic lymphocytic leukemia 

DCAS Division of Compensation Analysis and Support 

DCF dose conversion factor

DOL (U.S.) Department of Labor 

DR Dose Reconstruction 

EE Energy Employee 

FMPC Feed Materials Production Center 

ICD International Classification of Diseases 

ICRP International Commission on Radiological Protection 

IMBA Integrated Modules of Bioassay Analysis 

IREP Interactive RadioEpidemiological Program 

keV kiloelectron volts 

NCI National Cancer Institute 

NIOSH National Institute for Occupational Safety and Health 

NOCTS NIOSH/OCAS Claims Tracking System 

NOS not otherwise specified 

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team 

PC page change 

PER Program Evaluation Report

POC or PoC Probability of Causation 

PRSC Procedures Review Subcommittee 

rem Roentgen equivalent man

SC&A S. Cohen and Associates (SC&A, Inc.) 

SRS Savannah River Site 

TBD Technical Basis Document 

TIB Technical Information Bulletin
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1.0 RELEVANT BACKGROUND INFORMATION 

S. Cohen and Associates (SC&A) was tasked by the Advisory Board to conduct a review of 

DCAS-PER-043, Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code Revisions. ORAUT-OTIB-0005 provides guidance on selection of 

(1) the appropriate International Commission on Radiological Protection (ICRP) organ or tissue 

model to estimate the internal dose for specific ICD-9 Codes, (2) the appropriate organs or 

tissues to estimate external dose, and (3) the appropriate model in the Interactive 

RadioEpidemiological Program (IREP). ORAUT-OTIB-0005 also provides information for 

selecting and assessing likely primary cancers for secondary cancers. 

Revision 00 of ORAUT-OTIB-0005 was first issued on November 3, 2003 (ORAUT 2003), 

which was followed by four revisions and four page-change (PC) revisions, with the issuance of 

Rev. 05 on December 20, 2012 (ORAUT 2012b). While some changes in each of the revisions 

increased doses, others reduced doses. Since corrective actions mandated by DCAS-PER-043 

only need to consider those changes that could result in an increase in dose, the National Institute 

for Occupational Safety and Health (NIOSH) only considered those revisions that had the 

potential to increase the dose/probability of causation (POC) of previously completed claims, as 

summarized below: 

 Revision 01 (ORAUT 2004a) incorporated guidance for the selection of the external

organ for a given ICD-9 Code into ORAUT-OTIB-0005, which was previously contained 

in OCAS-IG-001. This revision did not introduce a change to the estimate of the organ 

dose. 

 Revision 01 PC-1 (ORAUT 2004b) added the bone cancer model as a possible option to 

ICD-9 Code 238.7 [lymphoproliferative disease, not otherwise specified (NOS)]. 

 Revision 01 PC-2 (ORAUT 2004c) changed the designated internal organ for codes 

231.8, 235.8, and 235.9 from lung to “medical review.”

1

 Revision 01 PC-3 (ORAUT 2004d) introduced two changes, both of which resulted in a 

decrease in dose and are, therefore, not impacted by DCAS-PER-043.

 Revision 02 (ORAUT 2005) modified handling adenocarcima of the lower third of the 

esophagus. The revised method required modeling of the esophagus and the stomach to 

determine which is higher. 

 Revision 02 PC-1 (ORAUT 2006) updated Table 3-1 to reflect guidance in OCAS-TIB012, Rev. 1 (OCAS 2006) (internal and external organs for ICD-9 series 200 through 204 

changed from “Reserved” to the specified organ).

 

1

 Due to the complexity of determining the appropriate internal organ for some ICD-9 Code cancers, a 

medical review/recommendation by an Oak Ridge Associated Universities Team (ORAUT) physician is required for 

determination of internal organ. 
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 Revision 03 (ORAUT 2010) changed the internal organ for ICD-9 Code 155.1 

(malignant neo intrahepatic ducts) from gallbladder to liver/gallbladder. The liver is to 

be used for intrahepatic ducts; the gallbladder for gallbladder; and a medical review is 

required to determine the appropriate internal organ for any other specific organ. 

 Revision 04 (ORAUT 2011) changed internal and external target organs for ICD-9 Codes 

238.0 (uncert behave neoplasm nec/nos) and 239.2 (bone/skin neoplasm nos). The 

internal target organ changed from “medical review” to bone surfaces, and the 

external target organ changed from red bone marrow to bone surface. 

 Revision 05 (ORAUT 2012b) added ICD-9 Code 204.1 [chronic lymphocytic leukemia 

(CLL)] that is briefly described in ORAUT-OTIB-0082 (ORAUT 2012a) and in greater 

detail in Apostoaei and Trabalka (2012). 

On August 18, 2014, SC&A submitted to the Procedures Review Subcommittee (PRSC) our 

review of NIOSH’s program evaluation report (PER), DCAS-PER-043 (SC&A 2014). In 

conducting a PER review, SC&A is committed to perform five subtasks, as specified below: 

Subtask 1: Assess NIOSH’s evaluation/characterization of the “issue” and its potential impacts 

on dose reconstruction (DR). Our assessment intends to ensure that the “issue” was fully 

understood and characterized in the PER. 

Subtask 2: Assess NIOSH’s specific methods for corrective action. In instances where the PER 

involves a technical issue that is supported by document(s) [e.g., white papers, technical 

information bulletins (TIBs), procedures] that have not yet been subjected to a formal 

SC&A review, Subtask 2 will include a review of the scientific basis and/or sources of 

information to ensure the credibility of the corrective action and its consistency with 

current/consensus science. Conversely, if such technical documentation has been 

formalized and previously subjected to a review by SC&A, Subtask 2 will simply provide 

a brief summary/conclusion of this review process. 

Subtask 3: Evaluate the PER’s stated approach for identifying the universe of potentially 

affected DRs, and assess the criteria by which a subset of potentially affected DRs was 

selected for re-evaluation. The second step may have important implications in instances 

where the universe of previously denied DRs is very large and, for reasons of practicality, 

NIOSH’s re-evaluation is confined to a subset of DRs that, based on their scientific 

judgment, have the potential to be significantly affected by the PER. In behalf of 

Subtask 3, SC&A will also evaluate the timeliness for the completion of the PER. 

Subtask 4: Conduct audits of DRs affected by the PER under review. The number of DRs 

selected for audit for a given PER will vary. (It is assumed that the selection of the DRs 

and the total number of DR audits per PER will be made by the Advisory Board.) 

Subtask 5: Prepare a written report that contains the results of DR audits under Subtask 4, along 

with our review conclusions. 
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SC&A’s review of DCAS-PER-043 identified no findings. Specifically, our review found that 

(1) NIOSH’s selection criteria in the PER properly identified the population of claims requiring 

re-examination, and (2) SC&A agrees with the NIOSH corrective action approach taken in the 

PER. 

This report fulfills the requirement defined in Subtask 4, “Conduct audits of DRs affected by the 

PER under review.” In summary, changes introduced in ORAUT-OTIB-0005 affected a total of 

36 previously completed claims, which NIOSH re-evaluated. Of these, 2 claims resulted in a 

revised POC greater than 50%; the remaining claims resulted in revised POCs of less than 45% 

and represent the pool of claims from which a subset of DRs is selected for audit by SC&A. 

From a pool of 34 DRs subject to audit, SC&A recommended the selection of one claim from 

each of the following revisions and/or ICD-9 Codes: 

 Revision 02: ICD-9 Code 150. This change required the need to consider stomach 

cancer (both target organ and cancer model) for esophageal cancer of the lower third 

portion of the esophagus. Select one case from among four affected cases with 

reworked POCs of <50%. 

 Revision 03: ICD-9 Code 155.1. This changed specified liver as the appropriate internal 

dose organ for cases that had previously used the gall bladder. Select one case from 15 

affected claims with reworked POCs of <50%. 

 Revision 04: 

– ICD-9 Code 232 – added basal cell carcinoma to the considered cancer models for 

code 232 when cell type was not specified. Select one claim from 16 reworked 

claims with POCs of <50%. 

– ICD-9 Code 238 – changed target organs. Select the single claim that was reevaluated and resulted in a POC of <50%. 

The PRSC agreed with our recommendation for case selection and NIOSH forwarded to SC&A 

the list of 36 claims cited for re-evaluation in DCAS-PER-043 (see Exhibit 1). From this list, 

SC&A randomly selected the following three claims, one from each category: [Case B]; 

[Case C], and [Case D].

For the selection of the fourth case, there was but one claim involving ICD-9 Code 238. 

Exhibit 1 identifies this claim as [Case A]. 

As with all PER audits, SC&A’s review of re-evaluated claims under Task 4 is a focused review 

that is limited to corrective actions specified in DCAS-PER-043 in the reconstruction of dose. 

It should also be noted that, for 34 of the 36 cases impacted by revisions to ORAUT-OTIB-0005, 

NIOSH simply performed an internal evaluation of the cases, which was documented in a onepage MS Word file, and determined that the original dose reconstructions would result in a POC 
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<50%. Therefore, for these 34 claims, no formal DR reworks were performed and no revised 

DRs were submitted to the U.S. Department of Labor (DOL).

Presented in Sections 2.0 through 5.0 of this report is SC&A’s focused review to determine 

whether the applicable external doses and the internal doses associated with the four selected 

cases were re-evaluated by NIOSH in accordance with DCAS-PER-043.

Exhibit 1: List of Claims Reassessed by NIOSH under DCAS-PER-043

CODE Claim ID 

150 [Redacted]

150 [Redacted] originally ran as stomach; no rework necessary

150 [Redacted]

150 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

155.1 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted] org ran as BCC

232 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted]

232 [Redacted] org ran as BCC

232 [Redacted] org ran as BCC

232 [Redacted]

232 [Redacted]

232 [Redacted]

238 [Redacted]
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2.0 REVIEW OF DCAS-PER-043 ISSUES FOR [CASE A]

2.1 RELEVANT BACKGROUND INFORMATION

[Case A] represents an energy employee (EE) who worked at [redacted] from [redacted]

through [redacted]. The EE was diagnosed with a neuroendocrine carcinoma (Merkel cell 

cancer) of the chest wall in [redacted] (ICD-9 Code 209.35). It appears that an initial DR was 

conducted for the EE that was confined to the cancer with ICD-9 Code 209.35 diagnosed in 

2010.

Subsequently, this DR was revised and issued by NIOSH on April 22, 2011, in order to include 

the “second cancer” diagnosed on [redacted]. The “second cancer” was identified in the revised 

DR as anaplastic neuroendocrine carcinoma, metastatic to bone with the assigned ICD-9 

Code of 238.0.

Owing to Rev. 04 of ORAUT-OTIB-0005 (ORAUT 2011) and the issuance of DCAS-PER-043, 

which changed the internal target organ for Code 238 from “medical review” to bone surface, 

[Case A] met the criteria stated in PER-043 for a re-evaluation of dose and POC. Table 2-1 

identifies (1) organ doses assigned in the first DR revision (issued on April 22, 2011) for each of 

the two cancers, and (2) revised organ doses that addressed applicable changes to DR specified 

in DCAS-PER-043.

Table 2-1. Assigned Organ Doses to Claim [Case A] in Current DR Report Issued 

April 22, 2011, and PER-043 Revised Organ Doses

Dose Categories External

(rem)

Medical X-Ray

(rem)

Internal

(rem)

Total

(rem)

Neuroendocrine Carcinoma of 

the chest wall

(ICD-9 Code 209.35)

Current DR 1.217 1.901 1.833 4.951

PER Dose 1.074 0.595 0.132 1.801

Anaplastic Neuroendocrine 

Carcinoma, Metastatic to Bone 

(ICD-9 Code 238.0)

Current DR 0.921 0.540 1.918 3.379

PER Dose 1.095 0.831 17.991 19.917

Inspection of Table 2-1 shows that doses to the neuroendocrine carcinoma of the chest wall 

(ICD-9 Code 209.35) decreased from 4.941 rem to 1.801 rem. However, these changes were not

impacted by PER-043. For the anaplastic neuroendocrine carcinoma metastatic to bone (ICD-9 

Code 238.0), revisions under PER-043 increased the dose from 3.379 rem to 19.917 rem. When 

combined, PER-043 revised organ doses raised the POC from 8.18% to 35.23% 

2.2 SC&A’S COMMENTS/FINDINGS

SC&A reviewed the revised PER dose estimates for the second cancer with the ICD-9 Code 

238.0 and concluded the following: 

(1) Had the second cancer (with ICD-9 Code 238) been identified as a primary cancer, the 

revised PER-043 dose estimates would have been appropriate. 
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(2) However, the EE’s second cancer should have never been assigned the ICD-9 Code 

238.0, as explained below. 

Enclosed as Exhibit 2 is the first page of a fact sheet prepared by the National Cancer Institute 

(NCI) that identifies the etiology and defining features of a metastatic cancer. As cited in 

Exhibit 2, most notably is the fact that: 

. . . metastatic cancer has the same name and the same type of cancer cells as the 

original, or primary cancer. For example, breast cancer that spreads to the lung 

and forms a metastatic tumor is a metastatic breast cancer, not lung cancer. 

[Emphasis added.] 

Thus, the assignment of two different ICD-9 Codes for the EE’s two cancers (of which the 

second cancer was identified as, Anaplastic neuroendocrine carcinoma, metastatic to the bone) 

contradicts the very nature of a metastatic cancer. As stated in the NCI Fact Sheet, the EE’s 

“second/metastatic” cancer should have been assigned the ICD-9 Code of the primary cancer (or 

Code 209.35). 

In order to assess the circumstances under which this error occurred, SC&A reviewed records in 

the EE’s file and constructed the following timeline. (Note: Due to confidential and/or 

privileged information, some of the records will only be cited as a reference herein): 

(1) Some time prior to April 4, 2011, [Case A] had been returned by OCAS to DOL due to 

an additional cancer with ICD-9 Code 238.0, which requires a medical review.

(2) On April 4, 2011, an email was submitted by DOL that acknowledged the need for a 

“medical review” regarding the EE’s additional cancer. Distribution included Dr. Ronald 

E. Goans, PhD, MD, MPH, Senior Medical Consultant, as well as DOL and ORAUT 

staff members.

(3) On April 6, 2011, Dr. Goans forwarded his “medical review” (see Exhibit 3) of the EE’s 

additional cancer with ICD-9 Code 238.0, along with the following conclusions:

In my professional opinion, the anaplastic neuroendocrine tumor metastatic to 

the bone is a secondary metastatic tumor, undifferentiated from the primary 

Merkel cell tumor of the chest wall. I think the ICD code of the primary 

appears to be correct and I have not tried to change the ICD code for the 

metastatic tumor. I will be happy to do so if you choose, but I generally do 

not change ICD codes on my own. 

(4) On April 7, 2011, a “note to reviewers” (Exhibit 4) was forwarded that acknowledged the 

“metastatic” nature of the secondary cancer and the fact that the “. . . internal organ 

applied to the bone cancer was the same as that applied to the Merkel call [sic] cancer 

(skin).” [Emphasis added.]
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(5) In spite of the medical review, which emphatically identified the second cancer as a 

metastatic cancer, the first revision to the EE’s Dose Reconstruction Report issued on 

April 22, 2011, correctly identifies the EE’s additional cancer as “. . . Anaplastic 

neuroendocrine, carcinoma, metastatic to bone,” but Dr. Goans’ recommendation to 

change the ICD-9 Code of 238.0 of the second cancer to the ICD-9 Code 209.35 of the 

primary cancer was ignored. 

In summary, based on conclusions stated in the medical review (see Exhibit 3), which identified 

the EE’s “additional” cancer as a metastatic cancer derived from the EE’s primary cancer (i.e., 

Merkel cell tumor of the chest wall), SC&A identified the following two findings: 

Finding #1: Failure to revise the ICD-9 Code 238.0 to that of the primary cancer, Code 209.35. 

Had the ICD-9 code for the “metastatic” cancer been changed to 209.35, [Case A] would not

have required re-evaluation under the stated criteria of DCAS-PER-043.

Finding #2. As a metastatic cancer for which the primary cancer (i.e., Merkel cell tumor of the 

chest wall) was identified, there was neither a need to assess the dose to the metastatic cancer 

(since it is essentially identical to that of the primary cancer), nor include such a dose for the 

calculation of the POC. 
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Exhibit 2: Metastatic Cancer Fact Sheet (Page 1) – National Cancer Institute

Metastatic Cancer 

Key Points 

 Metastatic cancer is cancer that has spread from the place where it first started to another 

place in the body. 

 Metastatic cancer has the same name and same type of cancer cells as the original 

cancer. 

 The most common sites of cancer metastasis are, in alphabetical order, the bone, liver, 

and lung.

1. What is metastatic cancer?

Metastatic cancer is cancer that has spread from the place where it first started to another 

place in the body. A tumor formed by metastatic cancer cells is called a metastatic tumor 

or a metastasis. The process by which cancer cells spread to other parts of the body is 

also called metastasis. 

Metastatic cancer has the same name and the same type of cancer cells as the original, 

or primary, cancer. For example, breast cancer that spreads to the lung and forms a 

metastatic tumor is metastatic breast cancer, not lung cancer.

Under a microscope, metastatic cancer cells generally look the same as cells of the 

original cancer. Moreover, metastatic cancer cells and cells of the original cancer usually 

have some molecular features in common, such as the expression of certain proteins or 

the presence of specific chromosome changes. 

Although some types of metastatic cancer can be cured with current treatments, most 

cannot. Nevertheless, treatments are available for all patients with metastatic cancer. In 

general, the primary goal of these treatments is to control the growth of the cancer or to 

relieve symptoms caused by it. In some cases, metastatic cancer treatments may help 

prolong life. However, most people who die of cancer die of metastatic disease. 

2. Can any type of cancer form a metastatic tumor? 

Virtually all cancers, including cancers of the blood and the lymphatic system (leukemia, 

multiple myeloma, and lymphoma), can form metastatic tumors. Although rare, the 

metastasis of blood and lymphatic system cancers to the lung, heart, central nervous 

system, and other tissues has been reported. 
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Exhibit 3: Memo from Ronald E. Goans RE: NIOSH [Case A]

From: Ronald E. Goans 

Sent: Wednesday, April 06, 2011 9:21 PM 

To: Karlene K. Dysland 

Cc: DRAssignments; Steven R. Reed; Susan L. Winslow; Jodie Phillips; Ronald E. Goans 

Subject: RE: NIOSH [Case A]

 

Hi Karlene and all,

I have reviewed claim [Case A] and supporting documents. In NOCTS we have the following notations:

Primary Neuroendocrine carcinoma of the chest well - Merkel cell tumor 2/19/2010 209.35

Primary (Secondary) Anaplastic neuroendocrine carcinoma to bone - Metastatic to bone 3/22/2011; (238.0)

In my professional opinion, the anaplastic neuroendocrine tumor metastatic to bone is a secondary metastatic tumor, 

undifferentiated from the primary Merkel cell tumor of the chest wall. I think the ICD code for the primary appears to 

be correct and I have not tried to change the ICD code for the metastatic tumor. I will be happy to do so if you 

choose, but I generally do not change ICD codes on my own.

Best regards,

Ron Goans

Ronald E Goans PhD, MD, MPH

Senior Medical Consultant, MJW Corporation

[Redacted]
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Exhibit 4: Note to Reviewers 

Note to reviewers, 

Based on the email from Dr. Goans stating “the anaplastic neuroendocrine tumor metastatic to 

bone is a secondary metastatic tumor, undifferentiated from the primary Merkel cell tumor of the 

chest wall” – the internal organ applied to the bone cancer was the same as that applied to the 

merkel call cancer (skin). 

Jodie Phillips 

04/07/2011 
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3.0 REVIEW OF DCAS-PER-043 ISSUES FOR [CASE B]

3.1 RELEVANT BACKGROUND INFORMATION

[Case B] represents an EE who worked at the [redacted] as a [redacted] for two time periods: 

[redacted] to [redacted]; and [redacted] to [redacted]. On [redacted], the EE was diagnosed 

with adenocarcinoma of the distal esophagus with the assigned ICD-9 Code 150.5.

NIOSH completed a DR for [Case B] on September 30, 2004. In the original DR, the doses to 

the distal esophageal tissue from external, medical, and internal exposures were estimated. 

Under Rev. 02 of ORAUT-OTIB-0005 (ORAUT 2005), NIOSH recalculated a dose of 

3.874 rem using the stomach as the internal and external organ. Exhibit 5 shows NIOSH’s onepage DR reassessment form, which offers a comparison of the original (identified as “current 

dose”) and the reassessed doses that reflect DCAS-PER-043.

Inspection of Exhibit 5 shows that when the “stomach” is considered as the default internal/ 

external organ and IREP model, the internal dose significantly increased. This increase, 

however, was offset by a nearly identical reduction of external and medical exposures, resulting 

in a POC value that decreased from 12.96% to 11.73%. 

3.2 SC&A’S COMMENTS AND FINDINGS

SC&A reviewed and compared derived external and internal dose estimates to the esophagus in 

the current DR to reassessed external and internal dose estimates to the stomach as an optional 

choice under DCAS-PER-043. In addition to the change in target organ from esophagus to 

stomach, there were several other changes that affected dose estimates, as stated in Exhibit 5. 

For external dose, most notable among these changes was the elimination of previously 

“assumed” external exposures to <30 keV photons from plutonium. This revision reduced 

external dose from 2.941 rem to 1.740 rem. For internal exposure, the DCAS-PER-043 revised 

dose estimate was based on ORAUT-OTIB-0018, which likely overestimated the dose. 

SC&A concludes that the revised DR for [Case B] complies with DCAS-PER-043 and other 

applicable guidance. There are no findings.
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Exhibit 5: NIOSH’s Reassessment Report for [Case B]

Claim [Case B]

Total assigned dose 

Dose Categories Current Dose (rem) PER Dose (rem)

External 2.941 1.740

Medical X-ray 0.496 0.382

Internal 0.348 1.662

Total 3.785 3.784

 

PoC

Previous PoC (%) Revised PoC (%)

12.96 11.73

External Dose Assigned: 

1. Current DR uses esophagus as the external organ of interest. The PER DR uses the stomach as 

the organ of interest. 

2. [redacted] workbook reproduced and labeled “[Case B]_ [redacted]_External Dosimetry 

Data”. Current site specific TBD utilized. 

3. Current DR applied dose from <30 keV to account for exposure to plutonium. PER DR assigns all 

dose as 30-250 keV, EE worked in lab, not in plutonium area. 

X-Ray Dose Assigned: 

1. X-ray dose applied from site specific TBD using stomach as organ of interest. 

Internal Dose Assigned: 

1. Current DR uses the esophagus as the internal organ of interest. The PER uses the stomach as 

the organ of interest for all IMBA runs. 

2. Environmental internal dose calculated using CADW. 

3. OTIB-0018 also applied to ensure an overestimate of internal dose. 
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4.0 REVIEW OF DCAS-PER-043 ISSUES FOR [CASE C]

4.1 RELEVANT BACKGROUND INFORMATION

[Case C] represents an EE who worked at the [redacted] from [redacted] through [redacted], 

as a [redacted]. The EE was diagnosed with a cholangiocarcinoma (bile duct) cancer (ICD 

Code 155.1) on [redacted].

NIOSH completed a DR for [Case C] on September 26, 2006, which was based on the 

assumption that (1) the external dose to the bile ducts was best determined by using the dose 

calculated for the bladder, and (2) the internal dose to the bile ducts was best determined by 

using the dose calculated for the gallbladder, as specified in Rev. 02 PC-1 of ORAUT-OTIB0005 (ORAUT 2006).

With Rev. 03 of ORAUT-OTIB-0005 issued on February 26, 2010, the following changes were 

made to the organs used for Code 155.1: (1) the external organ was changed from bladder to 

liver, and (2) the internal organ was changed from gallbladder to liver/gallbladder, along with the 

following footnote h: 

For ICD-9 code 155.1, for cancers that described as cancer of the intrahepatic 

ducts, select liver as the internal organ. For those that are described as 

gallbladder carcinoma, select gallbladder as the internal organ. If the 

description is unclear, a medical review should be conducted to determine the 

appropriate internal organ of interest. [Emphasis added.] 

Using the most current Rev. 05 of ORAUT-OTIB-0005 (ORAUT 2012b), NIOSH revised the 

original dose of 3.607 rem to 8.714 rem, which exclusively reflects the increase in internal dose 

from 0.309 rem to 5.417 rem, as shown in Exhibit 6. Exhibit 6 identifies that this increase in 

internal dose was the result of using the liver as the internal organ of interest instead of the 

gallbladder.
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Exhibit 6: NIOSH’s Reassessment Report for [Case C]

Claim [Case C]

Total assigned dose 

Dose Categories Current Dose (rem) PER Dose (rem)

External 3.257 3.257

Medical X-ray 0.041 0.041

Internal 0.309 5.417

Total 3.607 8.714

 

PoC

Current PoC (%) PER PoC (%)

16.67 24.84

External Dose Assigned: 

4. Current DR uses bladder as organ of interest. PER DR uses liver as organ of interest. Did not 

change assigned dose because a DCF of 1 for each energy range was assigned (claimantfavorable). 

5. There were no revisions to TBD since the completion of the current DR. 

X-rays 

1. There were no revisions to TBD since the completion of the current DR. 

Internal Dose Assigned: 

1. Current DR uses gallbladder as organ of interest. PER DR uses liver as organ of interest resulting 

in an increase in the assigned dose. 

2. There were no revisions to TBD since the completion of the current DR. 
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4.2 SC&A’S COMMENTS AND FINDINGS

The “current” DR completed on September 26, 2006, identified the cancer for [Case C] as 

“cholangiocarcinoma (Bile Ducts) with the assigned ICD-9 Code 155.1. For the reassessed 

DCAS-PER-043 dose, NIOSH retained the earlier designation of “cholangiocarcinoma.”

Given this description of the EE’s primary cancer, footnote h of ORAUT-OTIB-0005, Rev. 05 

states that “. . . If the description is unclear, a medical review should be conducted to determine 

the appropriate internal organ of interest.” [Emphasis added.]

SC&A reviewed records in behalf of [Case C] and was unable to determine if a medical review

had been requested in order to determine the appropriate internal organ.

The American Cancer Society (ACS 2014) identifies the fact that, for bile duct cancer 

(cholangiocarcioma), there are three general locations where cholangiocarcinoma arises in the 

bile drainage system (see Exhibit 7): 

 within the liver (intrahepatic) 

 just outside the liver (extrahepatic) also called perihilar located at the notch of the liver, 

where the bile ducts exit 

 far outside the liver (distal extrahepatic) near where the bile ducts enter the intestine. 

In the absence of a more definitive description of the EE’s primary cancer [described only as 

cholangiocarcinoma (bile ducts)], and the absence of a medical review (as specified in footnote h

of ORAUT-OTIB-0005, Rev. 05), it remains uncertain whether the EE’s cancer was an 

intrahepatic or extrahepatic bile duct cancer. Thus, the selection of the liver as the internal 

organ for the revised DR is unsupported (in the absence of a medical review) and may not be 

correct. 

Finding #3. In the absence of a medical review that would specify the bile duct cancer as 

extrahepatic, NIOSH’s selection of the liver as the appropriate internal organ is inappropriate and 

would obviate the need for [Case C] to be re-evaluated. 
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Exhibit 7: Bile Duct Cancer Description from American Cancer Society 

What is bile duct cancer? 

Bile duct cancer starts in a bile duct. To understand this cancer, it helps to know about the normal bile 

ducts and what they do.

About the bile ducts

The bile ducts are a series of thin tubes that reach from the liver to the small intestine. The major function 

of the bile ducts is to move a fluid called bile from the liver and gallbladder to the small intestine, where it 

helps digest the fats in food. 
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Exhibit 7: Bile Duct Cancer Description from American Cancer Society (continued)

Different parts of the bile duct system have different names. In the liver it begins as many tiny tubes 

(called ductules) where bile collects from the liver cells. The ductules come together to form small ducts, 

which then merge into larger ducts and eventually the left and right hepatic ducts. All of these ducts within 

the liver are called intrahepatic bile ducts. 

The left and right hepatic ducts exit from the liver and join to form the common hepatic duct in an area 

called the hilum. Lower down, the gallbladder (a small organ that stores bile) joins the common hepatic 

duct through a small duct called the cystic duct. The combined duct is called the common bile duct. The 

common bile duct passes through part of the pancreas before it joins with the pancreatic duct and 

empties into the first part of the small intestine (the duodenum) at the ampulla of Vater. 
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Exhibit 7: Bile Duct Cancer Description from American Cancer Society (continued)

Types of bile duct cancers by location

Cancers can develop in any part of the bile duct system and, based on their location (see picture 

below), are classified into 3 types:

 Intrahepatic bile duct cancers

 Perihilar (also called hilar) bile duct cancers

 Distal bile duct cancers

Cancers in these different areas can cause different symptoms.

Intrahepatic bile duct cancers 

These cancers develop in the smaller bile duct branches inside the liver. They can sometimes be 

confused with cancers that start in the liver cells, which are called hepatocellular carcinomas, and are 

often treated the same way. Only about 1 in 10 bile duct cancers are intrahepatic.
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Exhibit 7: Bile Duct Cancer Description from American Cancer Society (continued)

Perihilar (also called hilar) bile duct cancers 

These cancers develop at the hilum, where the left and right hepatic ducts have joined and are just 

leaving the liver. These are also called Klatskin tumors. They are the most common type of bile duct 

cancer, accounting for more than half of all bile duct cancers. These cancers are grouped with distal bile 

duct cancers as extrahepatic bile duct cancers.

Distal bile duct cancers 

These cancers are found further down the bile duct, closer to the small intestine. Like perihilar cancers, 

these are extrahepatic bile duct cancers because they start outside of the liver. Distal bile duct cancers 

make up 2 to 3 of every 10 bile duct cancers.

Types of bile duct cancer by cell type

Bile duct cancers can also be divided into types based on how the cancer cells look under the

microscope. 

Nearly all bile duct cancers are called cholangiocarcinomas. Most of these are adenocarcinomas, which 

are cancers that start in glandular cells. Bile duct adenocarcinomas develop from the mucous gland cells 

that line the inside of the duct.

Other types of bile duct cancers are much less common. These include sarcomas, lymphomas, and small 

cell cancers. This document does not discuss these other types of bile duct cancer.

The rest of this document refers only to cholangiocarcinomas.

Benign bile duct tumors 

Not all bile duct tumors are cancerous. Bile duct hamartomas and bile duct adenomas are examples of 

benign (non-cancerous) tumors, which aren’t discussed further in this document. 

Last Medical Review: 11/01/2014 

Last Revised: 11/01/2014
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5.0 REVIEW OF DCAS-PER-043 ISSUES FOR [CASE D]

5.1 RELEVANT BACKGROUND INFORMATION

[Case D] represents an EE who worked as a [redacted] at [redacted] from [redacted] through 

[redacted], and again from [redacted] through [redacted]. On [redacted], the EE was broadly 

diagnosed with “skin” cancer on the left hand.

On February 21, 2008, NIOSH completed its first DR that estimated a dose of 16.21 rem to the 

affected skin cancer, which was identified with the ICD-9 Code 232.6.

In Rev. 04 of ORAUT-OTIB-0005 (ORAUT 2011), the cancer model for Code 232 changed. 

Previously, both malignant melanoma and non-melanoma squamous cell carcinoma were to 

be assessed and the dose reconstructor was to select the one that produced the highest POC 

value. Revision 04 added basal cell carcinoma as a third option. 

In the original DR (i.e., prior to Rev. 04 of OTIB-0005), NIOSH had selected malignant 

melanoma as its choice of the cancer model. Under Rev. 4 of OTIB-0005 (ORAUT 2011) and 

PER-043, NIOSH reassessed the POC using the original estimate of skin dose (i.e., 16.21 rem), 

but selected the non-melanoma skin-basal cell cancer IREP model. 

This “change” in IREP model from malignant melanoma to non-melanoma skin basal cell

caused the POC to go from 25.04% down to 24.40%. 

5.2 SC&A’S COMMENTS AND FINDINGS 

In behalf of ICD-9 Code 232, footnote e states the following: 

. . . if the type of cancer is specified by DOL (“Malignant melanoma, Nonmelanoma skin-Squamous cell, or Non-melanoma skin-Basal cell”) use only the 

specified IREP model (note that Bowen’s disease is another name for squamous 

cell carcinoma in situ). If the cancer is not specified, run all listed IREP models 

as discussed in Section 4.6.

And Section 4.6 of ORAUT-OTIB-0005 (ORAUT 2011) states: 

For multiple IREP models that are connected by the word “AND”, separate IREP 

runs should be made for each listed model, and compensability is determined 

based on the model that results in the highest POC, which is favorable to the 

claimant. . . . [Emphasis added.] 

In order to determine whether all three IREP models had been considered as required by 

footnote e for selection of the highest POC value, SC&A reviewed the original DR (which had 

selected malignant melanoma). However, SC&A was unable to determine if the non-melanoma 

skin squamous cell model had been considered and eliminated as the IREP model yielding the 
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highest POC. For this reason, SC&A independently assessed the non-melanoma skin squamous 

cell IREP model, which yielded the lowest POC value.

SC&A concurs with NIOSH that, for [Case D], the IREP model malignant melanoma yields 

the highest POC value. Thus, there are no findings associated with [Case D].
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6.0 SUMMARY CONCLUSIONS

Under SC&A’s A Protocol to Review NIOSH’s Program Evaluation Reports (PERs), SCA-TRPR2009-0002, Rev. 1 (SC&A 2009), Subtask 4 requires the audit of DR cases reworked as a 

result of the PER under review. After SC&A’s review of DCAS-PER-043, Internal Dosimetry 

Organ, External Dosimetry Organ, and IREP Model Selection by ICD-9 Code Revision, it was 

determined by the PRSC that SC&A be tasked with reviewing four reworked claims. Selected 

for review were four cases representing discrete revisions to ORAUT-OTIB-0005 and select 

ICD-9 Codes, as described in Section 1.0 of this report.

SC&A’s review of the four cases identified the following:

 [Case A] – Two findings were identified that reflect the assignment of an incorrect ICD-9 

Code to a metastatic cancer that (1) triggered an independent dose estimate to the 

metastatic cancer, and (2) necessitated the re-evaluation of the case under DCAS-PER043 criteria.

 [Case B] – SC&A concurs with NIOSH’s re-evaluation, and there are no findings.

 [Case C] – SC&A identified one finding, which involved NIOSH’s selection of the 

internal organ that required a medical review.

 [Case D] – SC&A concurs with NIOSH’s re-evaluation, and there are no findings.
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REFERENCES

ACS (American Cancer Society) 2014. What is Bile Duct Cancer? 

http://www.cancer.org/cancer/bileductcancer/detailedguide/bile-duct-cancer-what-is-bile-ductcancer.

Apostoadi, A.I. and J.R. Trabbalka. 2012. Review, Synthesis, and Application of Information on 

the Human Lymphatic System to Radiation Dosimetry for Chronic Lymphocytic Leukemia, Final 

Report. SENES Oak Ridge, Inc., Center for Risk Analysis, Oak Ridge, Tennessee. March 2012.

DCAS-PER-043. 2012. Program Evaluation Report: Internal Dosimetry Organ, External 

Dosimetry Organ, and IREP Model Selection by ICD-9 Code Revision, Rev. 0, Division of 

Compensation Analysis and Support: Cincinnati, Ohio. June 7, 2013.

OCAS-IG-001. 2007. External Dose Reconstruction Implementation Guideline, Rev. 3, 

National Institute for Occupational Safety and Health, Office of Compensation Analysis and 

Support, Cincinnati, Ohio. August 7, 2007.

OCAS 2006. Selection for Internal and External Dosimetry Target Organs for Lymphatic/

Hematopoietic Cancers, OCAS-TIB-012, Rev. 1, Office of Compensation Analysis and Support 

(OCAS), NIOSH, Cincinnati, Ohio. February 10, 2006.

ORAUT 2003. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 00, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. November 3, 2003.

ORAUT 2004a. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 01, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. January 23, 2004.

ORAUT 2004b. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 01 PC-1, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. March 5, 2004.

ORAUT 2004c. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 01 PC-2, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. May 7, 2004.

ORAUT 2004d. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 01 PC-3, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. October 29, 2004.

ORAUT 2005. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 02, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. December 2, 2005.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

ORAUT 2006. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 02 PC-1, Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. February 10, 2006.

ORAUT 2010. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 03, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. February 26, 2010.

ORAUT 2011. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 04, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. April 18, 2011.

ORAUT 2012a. Dose Reconstruction Method for Chronic Lymphocytic Leukemia, ORAUTOTIB-0082, Rev. 00, Oak Ridge Associated Universities Team, Cincinnati, Ohio. December 4, 

2012.

ORAUT 2012b. Internal Dosimetry Organ, External Dosimetry Organ, and IREP Model 

Selection by ICD-9 Code, ORAUT-OTIB-0005, Rev. 05, Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. December 20, 2012.

SC&A 2009. A Protocol to Review NIOSH’s Program Evaluation Reports (PERs), SCA-TRPR2009-0002, Rev. 1, SC&A, Inc.: Vienna, Virginia. December 1, 2009.

SC&A 2014. Review of NIOSH’s Program Evaluation Report DCAS-PER-043, “Internal 

Dosimetry Organ, External Dosimetry Organ, and IREP Model Selection by ICD-9 Code, 

Contract No. 200-2014-58081, SCA-TR-PR2014-0089, Rev. 0, SC&A, Inc.: Vienna, Virginia. 

May 2013.